Five Fold Increase in Radioactivity Proposed for Lillyhall Landfill

images from Wastwater Chronicles “Signals for Survival!”

PRESS NOTICE

 

Five Fold Increase in Radioactivity Proposed for Lillyhall Landfill.

 
FCC Recycling who operate Lillyhall Landfill in Cumbria has applied to make changes to its Radioactive Substances Activities Permit. This includes a five fold increase of Tritium, a uniquely dangerous radioactive waste.
 
Background
Radiation Free Lakeland are a civil society group concerned with nuclear safety.  The group have been campaigning against the nuclearisation of Lillyhall Landfill site since 2008 when the law was changed to allow a new classification of ‘exempt’  High Volume Low Level Wastes into specified landfill.  RaFL argued that opening up Lillyhall Landfill to radioactive wastes no matter if they were ‘exempt’ would lead to accidental dumping of higher activity wastes and mission creep from the nuclear industry to dump ever higher activity decommissioning wastes.  In 2013 Sellafield were fined £700,000 for dumping unmarked plastic bags of low level and intermediate level wastes into Lillyhall.  The private company operating the Landfill site were not fined or reprimanded at all.  In summing up the case against Sellafield at Carlisle Court, the judge hearing the case recognised that the mistakes that were made indicated basic management failures and said “in this type of industry, it shouldn’t be the case that lessons are learnt after the event”.
 
Consultation
Despite scandalous failings at Lillyhall Landfill site, Cumbria County Council have decided that the operators do not require planning permission to hike up the increase in radioactivity five fold.
The Environment Agency are consulting the public on the increase to Lillyhall’s Landfill permit. Radiation Free Lakeland have written to the EA vehemently opposing any such increase and calling for the landfill to stop accepting radioactive wastes altogether.
 
The reasons RaFL cite for their opposition are:  
 
The most comprehensive report on tritium was published by the UK Government’s senior Advisory Group on Ionising Radiation (AGIR, 2008). 
 
This report strongly recommended that tritium’s hazard (ie, its radiation weighting factor) should be doubled from 1 to 2. 
 
However other scientists (Fairlie, 2008; Fairlie, 2007a; Fairlie, 2007b; Melintescu et al, 2007; Makhijani et al, 2006) have presented evidence for even larger increases in tritium’s radiotoxicity, including the US EPA (2006) which recommended a 2.5 fold increase in hazard.
 
Instead of reducing the activity limit allowed by 2.5 the operators of Lillyhall landfill are asking for a five fold increased activity limit.  
 
The Landfill operators ( under pressure from the Nuclear Decommissioning Authority?) ) are proposing a new more dangerous limit of 200 Bq per gram which is equivalent to 200,000 Bq per kilogram. 
 
One kg of water is the same as one litre of water. ie the new limit means 200,000 Bq per litre of water, 
There are several limits for tritium in DRINKING WATER.
 
The Lillyhall landfill site is just 200 metres from a potable fresh water supply. The photograph attached was taken on the 13th February 2019, the contractors saying that they were using the water to supplement nearby Workington.  In the same area as this potable water resource just 200 metres from the landfill is also David Woods Bakery and the nearby Lakes Academy.
 
Dr Ian Fairlie an expert on radiation in the environment points out that “in its elemental form, tritium diffuses through most containers, including those made of steel, aluminium, concrete and plastic. In the oxide form, tritium is generally not detected by commonly-used survey instruments”
 
ENDS
 
 
Sellafield Fined – Landfill Operators Get off Scot Free – Eye Witness Account of the Day in Court
FULL LETTER TO THE ENVIRONMENT AGENCY
 

 

 

Begin forwarded message:
From: marianne Birkby <>
Subject: FAO ……. Lillyhall, Landfill Permit Variation
Date: 23 April 2019 at 20:38:49 BST
To Environment Agency

 

Dear …… ,

Please find attached and below our letter of opposition to the proposed five fold increase in radioactive activity in the decommissioning wastes being sent to Lillyhall landfill from Sellafield, Chapelcross etc.
Also attached: The Hazards of Tritium Releases – by Dr Ian Fairlie
Thank you
Marianne Birkby
On behalf of Radiation Free Lakeland
April 23rd 2019
 
LILLYHALL LANDFILL
To the Environment Agency
Application from FCC Recycling (UK) Ltd to make changes to its Radioactive Substances Activities (RSA) Permit at the Lillyhall Landfill Site in Cumbria.
The proposed changes to the permit are as follows:
  • to increase the current activity limits for the disposal of radioactive waste in the permit from 4Bq/g (or 40 Bq/g for tritium) to a maximum average consignment activity limit of 200 Bq/g
Radiation Free Lakeland are a civil society group concerned with nuclear safety. We have consistently opposed the licensing of Lillyhall Landfill for the receipt of the nuclear industry’s High Volume Very Low Level Wastes (largely from decommissioning of Sellafield, Chapelcross and elsewhere). Now the industry wants a new designation to be put into Lillyhall of “Low Activity Low Level Waste.” It is clear that the the limits keep going up to facilitate ‘decommissioning.’ Lillyhall just 10 years ago received a relatively small amount yearly of Naturally Occurring Radioactive Materials from the oil and gas industry. 
We are shocked to see that Cumbria County Council have stated that planning permission will not be required for this new higher activity of nuclear waste going to Lillyhall landfill: “An opinion has been received from Cumbria County Council regarding the acceptance of LA-LLW, stating that planning permission would not be required.”
This appalling hand washing by Cumbria County Council regarding nuclear safety should not absolve the Environment Agency of responsibility for the public’s health and safety.
The operators of the landfill are (we presume under pressure from the Nuclear Decommissioning Authority) asking the Environment Agency for a hiked up increase in radioactive limits and in the case of tritium – a staggering five fold increase.
In recent years,10 major reports on tritium have been published by radiation safety agencies in the UK (AGIR, 2008), Canada (CNSC, 2010a; 2010b) and in France, the French Nuclear Safety Authority (ASN, 2010) has published a comprehensive White Paper on tritium and the French Institute de Radioprotection and Nuclear Safety has published six major reports on tritium (IRSN, 2010a; 2010b; 2010c; 2010d; 2010e; 2010f). 
In particular, the reports all noted that tritium exposures resulted in internal radiation doses whose estimation contained uncertainties which could render them unreliable. In other words there is zero evidence that Tritium is safer than before. Just the opposite.
The most comprehensive report on tritium was published by the UK Government’s senior Advisory Group on Ionising Radiation (AGIR, 2008). 
This report strongly recommended that tritium’s hazard (ie, its radiation weighting factor) should be doubled from 1 to 2. However other scientists (Fairlie, 2008; Fairlie, 2007a; Fairlie, 2007b; Melintescu et al, 2007; Makhijani et al, 2006) have presented evidence for even larger increases in tritium’s radiotoxicity, including the US EPA (2006) which recommended a 2.5 fold increase in hazard.
Instead of reducing the activity limit allowed by 2.5 the operators of Lillyhall landfill are asking for a five fold increased activity limit.
The Landfill operators ( under pressure from the Nuclear Decommissioning Authority?) ) are proposing a new more dangerous limit of 200 Bq pergramwhich is equivalent to 200,000 Bq perkilogram.
One kg of water is the same as one litre of water. ie the new limit means 200,000 Bq per litre of water, 
The reason for expresssing it in this way us that there are few limits for tritium in soil but there are several limits for tritium in DRINKING WATER, 
The Lillyhall landfill site is just 200 metres from a potable fresh water supply. The photograph attached was taken on the 13th February 2019, the contractors saying that they were using the water to supplement nearby Workington. In the same area as this potable water resource just 200 metres from the landfill is also David Woods Bakery.
Dr Ian Fairlie an expert on radiation in the environment points out that “in its elemental form, tritium diffuses through most containers, including those made of steel, aluminium, concrete and plastic. In the oxide form, tritium is generally not detected by commonly-used survey instruments”
To compare the Landfill’s suggested increase of 200,000 Bq per litre with the international reports on Tritium see below. 
.Tritium Concentration Limits in drinking water – Bq per litre
AGENCY
DATE
TRITIUM LIMIT BQ PER LITRE
Ontario Government’s Advisory Committee on Environmental Standards
1994
20*
EC (European Commission,1998)
1998
100
US State of Colorado target
2008
18
US State of California target
2008
15
Ontario Government (ODWAC,2009)
2009
20
CNSC design guide for groundwater (CNSC,2011)
2011
100
Is the health and safety of West Cumbria of such less worth than the rest of the world?
Lillyhall Industrial Estate was, just a decade ago free from nuclear licensed sites. Now there is the Metal Recycling Facility, the Energy Coast Laundry and Lillyhall Landfill. Lillyhall should not be used as a radioactive ghetto for the use of Sellafield and other nuclear plant decommissioning wastes.
Radiation Free Lakeland vehemently oppose not only any increase in the activity of Radioactive Waste going onto the Lillyhall site but we also continue to call for an end to the morally bankrupt use of Lillyhall Landfill and the Lillyhall Industrial Estate (which also houses the Lakes College) as a nuclear industry dumping ground. 
Yours sincerely,
Marianne Birkby
On behalf of Radiation Free Lakeland
 Notes 
Attached report by Dr Ian Fairlie 
The Hazards of Tritium Releases 
Extract
  1. The most comprehensive report on tritium was published by the UK Government’s senior Advisory Group on Ionising Radiation (AGIR, 2008). This report strongly recommended that tritium’s hazard (ie, its radiation weighting factor) should be doubled from 1 to 2. However other scientists (Fairlie, 2008; Fairlie, 2007a; Fairlie, 2007b; Melintescu et al, 2007; Makhijani et al, 2006) have presented evidence for even larger increases in tritium’s radiotoxicity, including the US EPA (2006) which recommended a 2.5 fold increase.
  1. These reports draw attention to tritium’s properties which mark it out as an unusually hazardous radionuclide. These include
    1. its relatively long half life of 12.3 years
    2. its mobility and cycling (as H2O)in the biosphere, 
    3. its multiple pathways to man, 
    4. its ability to swap instantaneously with H atoms in adjacent materials, 
    5. its relatively high relative biological effectiveness (RBE) of 2 to 3, 
    6. its binding with cell constituents to form organically-bound tritium (OBT)with heterogeneous distribution in humans, and
    7. its short-range beta particle, meaning that its damage depends on location within cellular molecules, e.g.DNA
  1. For these reasons, tritium presents several challenges to conventional dosimetry and health-risk assessment. Also, in its elemental form, tritium diffuses through most containers, including those made of steel, aluminium, concrete and plastic. In the oxide form, tritium is generally not detected by commonly-used survey instruments(Okada et al, 1993).

One thought on “Five Fold Increase in Radioactivity Proposed for Lillyhall Landfill

  1. Caroline Hope

    Having now read your press release: Five Fold increase in Radioactivits proposal for Lilleshall Landfill, that tritium can be sent to landfill and does not require ‘planning permission’ I have a better understanding of why people were being asked to surround Springfield, even without this there are plenty of reasons for doing so. This further criminal proposal is astounding, even for nuclear.

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